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2026 FAMILY, PRIVATELY OWNED AND OWNER-MANAGED BUSINESS SURVEY

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Contractual Disclosure Facility

Contractual Disclosure Facility (CDF) – COP 9

This is the most intrusive type of enquiry because if you are subject to an enquiry conducted under Code of Practice 9, HMRC suspect you have been involved in tax fraud i.e. that you have not disclosed all of your income. If they suspect this is the case the first you will be aware of it is the letter from HMRC headed 'Tax Fraud', and this can be a very worrying time. Other enquiries can grow into a COP 9 enquiry because new information comes to light which leads HMRC to believe that tax has been deliberately avoided, however, in both circumstances the situation is the same. HMRC will seek to conduct their own investigation into your financial affairs unless you take control.

Enquiries conducted under COP 9 do offer taxpayers immunity from prosecution, so they do give that peace of mind although this is dependant on the taxpayer providing all relevant information to HMRC. This is where the experience of a professional is vital, especially one with extensive experience of this type of work.

We have dealt with many of these enquiries and can take much of the stress you will undoubtedly feel when faced with an enquiry under COP 9. We will meet with you to obtain the facts and be there at each meeting with HMRC to guide you through the process.

If you have received a letter from HMRC or you would like to make a voluntary disclosure to HMRC regarding your tax affairs please contact us.

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